To:

1. The Board of Directors of Banks conducting conventional business activities; and
2. The Board of Directors of Banks conducting business activities based on Sharia principles
   at their respective locations.

COPY

CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY NUMBER 6/SEOJK.03/2015

REGARDING

OFFICELESS FINANCIAL SERVICES IN THE CONTEXT OF INCLUSIVE FINANCE BY BANKS

In light of the effectiveness of the Financial Services Authority Regulation Number 19/POJK.03/2014 concerning Officeless Financial Services in the Context of Inclusive Finance (State Gazette of the Republic of Indonesia Year 2014 Number 350 and Supplement to the State Gazette of the Republic of Indonesia Number 5628), hereinafter referred to as POJK Laku Pandai, it is necessary to further regulate the implementation of Officeless Financial Services in the Context of Inclusive Finance by Banks in this Circular Letter of the Financial Services Authority as follows:

I. GENERAL PROVISIONS

A. Officeless Financial Services in the Context of Inclusive Finance, hereinafter referred to as Laku Pandai, is the activity of providing banking services and/or other financial services that are not conducted through a branch network, but through cooperation with other parties and must be supported by the use of information technology infrastructure.

B. In implementing Laku Pandai, Banks that will become organizers of Laku Pandai must not only meet the requirements but must also obtain prior approval from the Financial Services Authority. Banks that have obtained approval from the Financial Services Authority are hereinafter referred to as Organizing Banks. In this regard, the requirements and procedures for approval to become an Organizing Bank need to be further regulated.

C. For risk control in the implementation of Laku Pandai, particularly regarding the employment relationship between the Organizing Bank and Agents, regulations are needed regarding requirements, selection procedures, scope of cooperation agreements, as well as standards and mechanisms of the working relationship between the Organizing Bank and Agents.

D. Information technology infrastructure required to support the implementation of Laku Pandai must be reliable, secure, and tested technology, which is reflected, among others, in the availability of systems capable of recording transactions in real-time during the transaction, accompanied by security mechanisms starting from the system, data, and network, as well as the existence of adequate monitoring and evaluation mechanisms for the information technology infrastructure for the provision of services to customers.

E. So that the community to be served by Laku Pandai activities can recognize, be interested in, and be attracted to use the financial products and services provided by the Organizing Bank, the provision of education regarding financial products and services in this service is an absolute requirement for the Organizing Bank to perform. This education must be followed by activities aimed at customer protection, such as providing information to obtain optimal service benefits and protection from practices that can cause harm.

II. SAVINGS WITH BASIC SAVING ACCOUNT (BSA) CHARACTERISTICS

One of the Laku Pandai products provided by the Organizing Bank is savings with BSA characteristics.

A. BSA characteristics are as follows:

1. can only be owned by individual Indonesian citizens;
2. in Rupiah currency;
3. without minimum deposit limits;
4. without minimum account balance limits;
5. the maximum account balance limit at any time is set at most Rp20,000,000.00 (twenty million rupiah);
6. the maximum debit transaction limit of the account in the form of cash withdrawals, transfers, and/or outgoing transfers cumulatively in 1 (one) month for each account is at most Rp5,000,000.00 (five million rupiah).
   Definition of 1 (one) month is 1 (one) calendar month;
7. the maximum debit transaction limit of the account as referred to in item 6 can be set by the Organizing Bank to be larger than Rp5,000,000.00 (five million rupiah) in 1 (one) month, but must not exceed Rp60,000,000.00 (sixty million rupiah) in 1 (one) year cumulatively, in the event that the customer is also a debtor of the Organizing Bank.
   Definition of 1 (one) year is 1 (one) calendar year.

Example:
Y is a customer owning a savings account with BSA characteristics at Bank A (conventional bank) who has an initial balance of Rp3,000,000.00 (three million rupiah) and is also a debtor of a micro-credit loan from the same Bank, with a credit limit of Rp10,000,000.00 (ten million rupiah) approved on January 12, 2015. The disbursement of the credit is carried out by Bank A through Y's BSA on January 15, 2015, and January 19, 2015. Subsequently, Y makes a cash withdrawal of Rp11,000,000.00 (eleven million rupiah) to pay for production raw materials. In this case, Bank A may allow Y to carry out the said credit disbursement transaction even though it exceeds the BSA debit transaction limit in 1 (one) month, provided that the total BSA debit transactions during 2015 do not exceed Rp60,000,000.00 (sixty million rupiah).

As an illustration of the details of financial transactions that Y can carry out during 2015, among others:

Time	Transaction	Amount
January 2, 2015	Initial Balance	Rp3,000,000.00
January 15, 2015	Transfer in the context of credit disbursement	Rp8,000,000.00
January 16, 2015	Cash withdrawal to pay for production raw materials	(Rp11,000,000.00)
January 19, 2015	Transfer in the context of credit disbursement	Rp2,000,000.00
February 2015 to November 2015	Total account debit transactions	(Rp20,000,000.00)
February 2015 to November 2015	Total incoming transfers from sales results	Rp35,000,000.00
December 16, 2015	Transfer in the context of credit repayment	(Rp10,700,000.00)
December 16, 2015	Final Balance	Rp6,300,000.00

As of December 16, 2015, Y's account debit transactions reached Rp41,700,000.00 (forty-one million seven hundred thousand rupiah), so it does not contradict the maximum account debit transaction limit set for savings with BSA characteristics;

8. is exempt from charges for:
   a. monthly administration, b. account opening,
   c. cash deposit transactions,
   d. incoming transfer transactions, e. transfer transactions, and f. account closure;
9. fees for cash withdrawal transactions, outgoing transfers, payments through savings accounts, and other fees are set by the Organizing Bank and must be less than fees for similar transactions for regular savings accounts.

Example:
a. payment transactions through savings accounts such as electricity subscription fees, smart electricity purchases, water subscription bill payments, and/or telephone bill payments, and/or b. other fees including those for replacement of damaged or lost cards;
10. earns interest or profit sharing starting from an account balance of Rp1.00 (one rupiah). For BSA characteristic savings based on wadi'ah contracts, the Organizing Bank may provide voluntary (not agreed upon initially) savings bonuses; and
11. joint accounts with "and/or" status are not permitted.

Joint accounts with "and" status are permitted in the event that the prospective customer is an individual who has not yet met the requirements to possess identity documents such as an ID card and/or driver's license, for example, students. The individual may open a savings account with BSA characteristics by submitting identity document substitutes such as a student ID card accompanied by identity documents and a letter of consent from parents or guardians. In the event that the individual is accompanied by a guardian, the guardian must have met the provisions of applicable laws and regulations.

Joint accounts with "and" status as mentioned above are considered separate accounts and are not counted towards the maximum BSA ownership limit for parents.

B. The Organizing Bank may allow customers to carry out account debit transactions exceeding the maximum account debit transaction limit as referred to in letter A item 6 and/or letter A item 7, in the event of force majeure and/or extraordinary events outside the customer's control. Force majeure and/or extraordinary events include, among others, floods, fires, earthquakes, accidents, and/or bereavement.

Example:
Bank XYZ sets the maximum limit for cash withdrawals, transfers, and/or outgoing transfers in 1 (one) month at Rp2,000,000.00 (two million rupiah). P is a customer owning a savings account with BSA characteristics at Bank XYZ who has made cash withdrawals totaling Rp1,000,000.00 (one million rupiah) up to May 11, 2015. On May 12, 2015, P must make an outgoing transfer to pay hospital costs for their family in another city amounting to Rp2,000,000.00 (two million rupiah). Bank XYZ can grant an exemption policy to P and carry out an outgoing transfer of Rp2,000,000.00 (two million rupiah) on May 12, 2015, without changing the savings status, as long as Bank XYZ approves the request to exceed the maximum debit transaction limit submitted by P.

C. In the event that the number of account debit transactions exceeds the maximum limit as referred to in letter A item 6, letter A item 7, and/or the balance exceeds the maximum account balance limit as referred to in letter A item 5, and the customer still wishes to carry out transactions and/or increase the account balance, the Organizing Bank may change the status of the savings account with BSA characteristics to a regular savings account after:

1. The Organizing Bank first requests confirmation or approval from the customer owning the savings account with BSA characteristics.
   The request for confirmation or approval by the Organizing Bank is carried out as follows:
   a. can be done through the customer's electronic device and/or through Agents. b. The Organizing Bank sets:

   1. the nominal balance limit of the savings account with BSA characteristics before reaching the maximum balance as referred to in letter A item 5 or the maximum balance set by the Organizing Bank, and/or
   2. the nominal transaction limit of the account debit before reaching the maximum account debit transaction limit as referred to in letter A item 6, letter A item 7, or the maximum account debit transaction limit set by the Organizing Bank,
      as a reference for the Organizing Bank to determine the timing of sending the confirmation approval request to the customer.
      c. The Organizing Bank sets the time limit for submitting confirmation approval or rejection of the status change of the savings account by the customer owning the savings account with BSA characteristics to the Organizing Bank.
      d. The Organizing Bank ensures that if confirmation or approval is given by the customer owning the BSA characteristic savings account through electronic media, it must be followed by written confirmation; or

2. The Organizing Bank grants approval for the request of the customer owning the savings account with BSA characteristics to change the status of the savings account with BSA characteristics to a regular savings account.
   The granting of approval by the Organizing Bank is carried out as follows:
   a. The Organizing Bank sets the time limit for submitting confirmation approval or rejection of the status change of the savings account to the customer owning the savings account with BSA characteristics. b. in the event that approval for the request of the customer owning the savings account with BSA characteristics is given by the Organizing Bank through electronic media, it must be followed by written confirmation.

Example:
Bank H has the following policy:

• the maximum balance limit of the savings account with BSA characteristics at any time is at most Rp6,000,000.00 (six million rupiah),
• the nominal balance limit of the savings account with BSA characteristics as a reference for the Organizing Bank to send the confirmation approval request to the BSA customer (reference limit) is Rp5,500,000.00 (five million five hundred thousand rupiah), and
• sets mobile phones as electronic devices for all customers owning savings accounts with BSA characteristics.

C is a customer owning a savings account with BSA characteristics at Bank H who routinely saves Rp150,000.00 (one hundred fifty thousand rupiah) from the remaining profits of their business activities. As of May 11, 2015, C's savings balance had reached Rp5,500,000.00 (five million five hundred thousand rupiah).

In relation to C's savings balance reaching the reference limit, Bank H informs C, among others, through Short Message Services (SMS), that their savings balance is approaching the maximum BSA balance limit, simultaneously requesting confirmation whether C is willing to change their savings status to a regular savings account. In the event that C agrees, C must fill out the application form related to the change of savings type from savings with BSA characteristics to regular savings, accompanied by the submission of a photocopy of C's latest identity card and supporting documents required by Bank H, through an Agent or at Bank H's office. In the event that C does not agree, Bank H provides an oral and/or written explanation that C can no longer make cash deposits or receive incoming transfers on the savings account with BSA characteristics, which could result in exceeding the maximum savings balance limit.

III. APPLICATION FOR IMPLEMENTATION OF LAKU PANDAI

A. Banks wishing to implement Laku Pandai must include the plan for the implementation of Laku Pandai in the Bank Business Plan (RBB) for the relevant year, which must contain at least the following information and explanations:

1. type and general overview of the implementation of Laku Pandai;
2. planned time for the implementation of Laku Pandai to begin;
3. the relationship between the implementation of Laku Pandai with the business strategy and expected benefits by the Organizing Bank;
4. identification of risks arising from and risk mitigation prepared for the implementation of Laku Pandai; and
5. the number and type of Agents targeted per year for the first 3 (three) years of implementation and for cooperation in the first year accompanied by details of district/city locations.

Example for the number and type of Agents submitted in Bank XYZ's RBB in 2015:

Year	Individual Agents	Legal Entity Agents
2016	100	1
2017	150	1
2018	250	3

Example for the list of districts or cities:

Year 2016
Asmat District, Papua Province
Merauke District, Papua Province
Ternate City, North Maluku Province

B. Subsequently, Banks as referred to in letter A must submit a letter of request for approval accompanied by supporting documents containing at least the following information:

1. general information regarding the implementation of Laku Pandai including, among others, explanation of products to be provided in Laku Pandai, planned time for product issuance, target market and/or customers, and planned or target transaction value in the first 1 (one) year;
2. benefits, costs, and risks for the Bank;
3. benefits, costs, and risks for customers and Agents;
4. planned scope of Agent services including their classification and Agent operational areas;
5. implementation procedures (Standard Operating Procedure/SOP), organizational structure and authority, including supervision from the head office and/or Bank branches in regions that are target locations for Agents;
6. results of analysis from the identification, measurement, monitoring, and control of risks inherent in the implementation of Laku Pandai and its risk mitigation plan, including among others the results of legal aspect analysis for the implementation of Laku Pandai;
7. planned policies and procedures related to the application of the Anti-Money Laundering and Counter-Terrorism Financing (APU and PPT) program, including the APU and PPT program run by Agents;
8. documents or draft documents regarding:
   a. transparency and education for Agents and customers including, among others, agreements between the Bank and customers and/or Agents, brochures, leaflets, and/or application forms, b. readiness of information technology infrastructure,
   c. readiness of risk management application, particularly to ensure the fulfillment of information security principles;
9. accounting information system including a brief explanation regarding the relationship between the Laku Pandai activity accounting information system with the Bank's overall accounting information system, and/or administrative recording systems;
10. results of examination and opinions from independent parties regarding product characteristics, adequacy of information technology security related to Laku Pandai, and compliance with applicable regulations and best practices in the field of information technology.

C. Deadline for Document Submission

Banks must submit a request for approval to implement Laku Pandai at least 60 (sixty) days before the target time for the implementation of Laku Pandai accompanied by supporting documents.

Example:
Bank A plans to implement Laku Pandai on July 31, 2015, then the request for approval must be submitted by Bank A to the Financial Services Authority before or on June 1, 2015. In the event that Bank A submits the request for approval on June 2, 2015, then the request for approval will not be processed further.

IV. IMPLEMENTATION OF REQUIREMENTS FOR LAKU PANDAI ORGANIZING BANKS

A. Banks that will submit a request for approval to become organizers of Laku Pandai must meet the following requirements:

1. be an Indonesian legal entity;
2. have a risk profile rating, operational risk level, and compliance risk rating of rating 1, 2, or rating 3;
3. have a branch network in the Eastern Indonesia Region and/or East Nusa Tenggara province; and
4. have supporting infrastructure to provide electronic transaction services for Bank customers in the form of:
   a. SMS banking or mobile banking, and b. internet banking or host to host.

B. The requirements as referred to in letter A item 3 are exempted for:

1. Banks owned by Regional Governments; or
2. Banks with headquarters outside DKI Jakarta province.

C. Until regulations governing risk management for Rural Credit Banks (BPR) or Sharia Rural Credit Banks (BPRS) are in effect, the requirements regarding risk profile as referred to in letter A item 2 for BPR or BPRS are as follows:

1. have core capital of more than Rp100,000,000,000.00 (one hundred billion rupiah);
2. have a healthy health rating during the assessment period in the last 1 (one) year;
3. have Non Performing Loan (NPL) or Non Performing Financing (NPF) of at most 5% (five percent) during the assessment period in the last 6 (six) months;
4. have a Minimum Capital Adequacy Ratio (KPMM) of at least 12% (twelve percent);
5. are not in a state of loss in the last 1 (one) year; and
6. have no violations of specific BPR or BPRS regulations.

D. While the Bank has been approved as an Organizing Bank, the requirements as referred to in:

1. letter A for commercial banks; or
2. letter A and C for BPR or BPRS,
   must remain fulfilled.

E. In the event that a Bank that has been approved as an Organizing Bank no longer meets one or more of the Organizing Bank requirements as referred to in letter A or C, such as experiencing higher risk so that the risk profile rating no longer meets the requirements, then the Financial Services Authority can take supervisory actions by referring to applicable regulations such as restrictions on adding new agency cooperation or other supervisory actions.

V. COOPERATION FOR THE IMPLEMENTATION OF LAKU PANDAI

A. Laku Pandai Agent Requirements

1. Individual Agents must meet at least the following requirements:
   a. reside in the location where Laku Pandai is implemented; b. have good ability, reputation, credibility, and integrity. Ability includes at least:
   1. knowledge and understanding of the Bank's institution and products or services so that they can provide good explanations in carrying out their activities,
   2. ability to use electronic devices to serve customer transactions including explaining the use of electronic devices and/or instruments to customers,
   3. ability to make simple bookkeeping and manage personal finances, and
   4. ability to place a certain amount of deposits and/or guarantees in an amount as determined by the Organizing Bank.
      Reputation can be seen, among others, from the level of community recognition of the individual due to position, influence, or other factors such as customary leaders, religious figures, association managers, and/or educators. Credibility and integrity can be seen, among others:
   5. having a good track record in various activities such as never failing to fulfill obligations, having no bad credit, not listed in the National Blacklist (DHN), and/or never having committed criminal acts that have been decided by a court with permanent legal force,
   6. never having been declared bankrupt or being a manager who was declared guilty causing a company to be declared bankrupt,
   7. having a high commitment to comply with laws and regulations,
   8. not violating applicable regulations in the place where the prospective Agent obtains their main source of income related to providing services to Laku Pandai customers,
   9. having financial capability, and/or
   10. actively conducting banking transactions within a certain period;
       c. have a main source of income derived from business activities and/or other stable activities for at least 2 (two) years;
       The continuity of the main source of income or other ongoing activities is proven by:
   11. appointment letter as a permanent employee, business license from the competent authority, or letter of certification from the local government head at least from the head of the neighborhood association (RT) or customary leader, for individual individual Agents, or
   12. letter...

2. business license, company registration certificate, or business certificate/business domicile certificate from the competent authority, for individual agents or business entities;
   d. have not become an Agent of an Organizing Bank whose business activities are similar; and e. have passed the due diligence process in accordance with the policies and procedures owned by the Organizing Bank.

2. Legal entity Agents must meet at least the following requirements:
   a. be an Indonesian legal entity that:

1. is supervised by regulatory and supervisory authorities and is permitted to conduct activities in the financial sector, or
2. is a trading company that has a retail outlet network.
   Examples of legal entities include PT POS Indonesia, PT Pegadaian (Persero), and cooperatives.
   The term "retail outlet network" refers to a network of branch offices in the form of shops or business premises owned by the legal entity; b. have a good reputation, credibility, and business performance. Reputation can be seen, among others, from the good level of recognition by the public towards the legal entity and the many visits and transactions conducted by the surrounding community at the business premises of the prospective legal entity Agent. Credibility can be seen, among others, from the good track record of the legal entity, such as never failing to fulfill obligations, never being declared bankrupt, the management of the legal entity never committing disgraceful acts, and/or the legal entity not violating regulations regarding agency activities. Business performance includes, among others, having sufficient capital, financial capability reflected in specific financial ratios, liquidity management, and/or conducting active financial transactions within a certain period;
   c. have a business that is established in one location and is still ongoing for at least 2 (two) years.
   The continuity of business activities with a fixed location for at least 2 (two) years is proven by documents such as articles of association, business license, business domicile certificate/domicile permit, and/or company registration certificate. The requirement for a business to be established for at least 2 (two) years applies to the Head Office of the Agent; d. be able to perform liquidity management as required by the Organizing Bank. Liquidity management capability is reflected, among others, in the existence of policies and procedures regulating the periodic withdrawal and delivery of cash to and from the retail outlet network owned as part of the liquidity monitoring system; e. be able to provide human resources (HR) with technical capabilities to support the implementation of Laku Pandai. The ability to provide HR is reflected, among others, in the existence of policies and procedures for the recruitment, training, placement, and evaluation of HR, which are implemented well. Examples of technical capabilities to support the implementation of Laku Pandai include having:
3. knowledge and understanding of the Bank's institution and products or services in carrying out its activities,
4. the ability to use electronic devices to serve customer transactions in accordance with the Organizing Bank's SOP,
5. good communication skills to explain Bank products and services as well as the use of electronic devices and/or instruments to customers; and
   f. pass the due diligence process conducted by the Organizing Bank in accordance with the policies and procedures owned by the Organizing Bank.

3. Individual Agents or retail outlet networks of legal entity Agents may only provide products from 1 (one) conventional bank and/or 1 (one) Sharia bank.
   Included in the Sharia bank as referred to above is the network of offices of the Sharia Business Unit (UUS). The definition of UUS is as regulated in provisions regarding Sharia business units. Examples:
   a. Agent B (individual) has collaborated with Bank XYZ (conventional bank) since May 20, 2015, to provide BSA products from Bank XYZ. Because Agent B has good performance, at the beginning of June 2015, Agent B was recruited to become an Agent of Bank PQR (Sharia bank) and passed the due diligence process on June 18, 2015. Given that Agent B only collaborates with 1 (one) conventional bank, Agent B can collaborate with Bank PQR to provide Sharia BSA products from Bank PQR. b. Agent D (individual) located in Merauke Regency has signed a cooperation agreement with the branch office of Bank ABC (conventional bank) and a cooperation agreement with the Sharia branch office of Bank ABC (UUS) to provide BSA products and Bank ABC's Sharia BSA products at its outlets. Agent D has good performance so Bank EFG (Sharia bank) is interested in collaborating with Agent D. Because Agent D has marketed BSA products and Bank ABC's Sharia BSA products, Agent D cannot collaborate with Bank EFG.
   c. Agent E (legal entity) has collaborated with Bank JKL (conventional bank that has a UUS). One of its branch offices located in Ciamis Regency, namely outlet 123, has provided BSA products and Bank JKL's Sharia BSA products. If subsequently Agent E collaborates with Bank PQR (general Sharia bank) and determines that the area for providing Bank PQR's Sharia BSA products includes Ciamis Regency, then the product cannot be provided at outlet 123 but can be provided at other branch offices of Agent E also located in Ciamis Regency, for example, outlet 212.

B. Laku Pandai Agent Due Diligence Procedures

1. The Organizing Bank must have adequate policies and procedures related to the recruitment and due diligence of Agents.
   Adequate means, among others, approved by the Director overseeing the unit or work unit that implements Laku Pandai activities, after receiving a recommendation from the risk management unit or work unit.
2. The Agent due diligence procedure must cover at least Agent requirements, methods for identifying individuals and/or legal entities that are potential Agents, and the selection process starting from the fulfillment of administrative requirements, standards for evaluating prospective Agents, up to the registration process after the appointment of the Agent.

C. Training and Education for Laku Pandai Agents

1. The Organizing Bank is required to provide training and education to Agents who have passed due diligence.
2. The training and education as referred to in item 1 with material coverage includes, among others:
   a. procedures for providing services to customers with savings accounts having BSA characteristics; b. procedures for using electronic devices used by Agents in providing services to customers with savings accounts having BSA characteristics;
   c. procedures for using electronic devices and/or instruments that will be used by customers to conduct financial transactions;
   d. security and confidentiality of customer data; e. handling problems related to the use of electronic devices; f. handling complaints from customers with savings accounts having BSA characteristics; g. Agent liquidity management; h. introduction to financial products and services (including benefits, risks, and costs related to the products);
   i. methods for recognizing genuine currency; and
   j. application of Customer Due Diligence (CDD) procedures and simplified CDD to customers.

D. Laku Pandai Agent Appointment Letters

1. The Organizing Bank issues an Agent appointment document in the form of an Agent appointment letter.
2. The Agent appointment letter as referred to in item 1 must contain at least the following information:
   a. name of the individual or legal entity owning the Agent outlet; b. name of the person in charge of the Agent outlet;
   c. address of the Laku Pandai business location;
   d. identification number (registered at the Organizing Bank) and the date of validity of the Agent's registration.
   The Agent's identification number must reflect that the Agent comes from a specific Organizing Bank, containing at least information such as the Organizing Bank's code and distinguishing between individual and legal entity Agents. The Organizing Bank's code refers to regulations regarding monthly Bank reports. The identification number is unique for each Agent outlet; e. photo of the person in charge of the Agent outlet; f. a statement from the Organizing Bank that the Agent has passed due diligence by the Organizing Bank, received training and education, and is appointed as a Laku Pandai Agent; g. the duration of the appointment as an Agent; h. name of the Organizing Bank and the Agent's operational area;
   i. logo of the Organizing Bank; and
   j. name and signature of the competent official of the Organizing Bank.
3. The format of the Agent appointment letter is adjusted to the Organizing Bank's policy while still considering information clarity and proportional design.
4. The Agent appointment letter must be displayed at the Agent's business location where it is easily visible to customers and prospective customers of the Organizing Bank.

E. Cooperation Agreement

1. Cooperation between the Organizing Bank and the Agent is embodied in a written agreement containing at least:
   a. rights and obligations of the Organizing Bank and the Agent.

1. Rights of the Organizing Bank include, among others:
   a) requesting reports from the Agent, and b) conducting supervision and examination of the Agent.
2. Obligations of the Organizing Bank include, among others:
   a) providing remuneration to the Agent, b) providing application systems for the implementation of Laku Pandai, and c) conducting education and training.
3. Rights of the Agent include, among others:
   a) receiving remuneration and receiving guidance, and b) receiving training and education from the Organizing Bank.
4. Obligations of the Agent include, among others:
   a) maintaining the confidentiality of the Organizing Bank and customer personal data, b) implementing SOPs established by the Organizing Bank, including in cases where certain conditions cause the Agent to be unable to operate, c) complying with regulations regarding the implementation of Laku Pandai applicable to the Organizing Bank, and d) submitting reports to the Organizing Bank, including in cases where there are customers suspected of committing acts related to crime, terrorism, or the distribution of illegal drugs; b. the scope of services that can be provided by the Agent, including minimum standard quality of service provision by the Agent;
   c. the determination of the Agent's operational work area;
   d. the classification of the Agent.
   For legal entity Agents, the Organizing Bank may determine different classifications for each of the Agent's retail outlets; e. the duration of cooperation and its renewal mechanism; f. the mechanism and working relationship between the Organizing Bank and the Agent, including, among others:
5. the structure and amount of remuneration which may be in the form of commission/fee and the procedure for paying remuneration to the Agent,
6. placement including the amount of deposit and/or guarantee of the Agent at the Organizing Bank,
7. Agent liquidity management,
8. the Agent's obligation to ensure the security and confidentiality of records, data, and documents received by it, including the confidentiality of the Organizing Bank and customer personal data,
9. the determination of the Organizing Bank's ownership rights over information/data received by the Agent from customers and the Organizing Bank,
10. the Organizing Bank's mechanism to verify or examine documents, records, and reports from the Agent,
11. the type of electronic devices established and systems prepared by the Organizing Bank for use by the Agent;
    g. conditions and procedures for changing the cooperation agreement; h. the determination of sanctions and the mechanism for imposing sanctions;
    i. conditions and procedures for terminating the cooperation agreement.
    Termination of the cooperation agreement includes early termination before the end of the agreement period, in case of considerations including, among others:
12. the legal entity Agent is in the process of liquidation or declared bankrupt by the court,
13. the Agent violates bank secrecy regulations and/or the obligation to keep customer personal data confidential,
14. the Agent no longer meets the requirements as an Agent, and/or
15. the Organizing Bank no longer meets the criteria for implementing Laku Pandai;
    j. procedures, including dispute resolution venues; and k. procedures and conditions for relocating the Agent.

2. For legal entity Agents that have a retail outlet network in the form of branches and franchises, in the event that the Organizing Bank wishes to collaborate with the franchisee (franchisee) of that legal entity, the collaboration with the franchisee must be embodied in a separate cooperation agreement from the cooperation agreement with the franchisor (franchisor).
   The term "franchise" refers to regulations from the competent authority regarding franchises.
3. In the event that the Organizing Bank collaborates with individual Agents such as teachers, laborers, or company employees, in carrying out activities as an Agent, they must not neglect their main duties.

F. Laku Pandai Agent Identification (Signage/Sign Board)

1. The Organizing Bank equips Agents with Agent identification.
2. The Agent identification as referred to in item 1 must contain at least the following information:
   a. identification number; b. Agent name and/or outlet name;
   c. logo of the Organizing Bank;
   d. "Laku Pandai" logo; and e. a statement that savings accounts with BSA characteristics are guaranteed by the Deposit Insurance Corporation (LPS).
3. The format and size of the Agent identification are adjusted to the Organizing Bank's policy while still considering, among others:
   a. a design that can represent the identity of the Organizing Bank and the Laku Pandai Agent; b. clear and easy-to-read writing; and
   c. size adjusted to the size of the Agent's business premises.
4. The Agent identification must be displayed at the Agent's business location where it is easily visible to customers and prospective customers of the Organizing Bank.
5. In the event that the Agent collaborates with more than one Organizing Bank and/or financial service institution, the placement of the Agent identification must still apply equal treatment and maintain healthy competition among the Organizing Banks and/or financial service institutions.

G. Location and Mechanism for Relocating Laku Pandai Agents

1. Agent Location
   a. The Agent's location must be situated in the same city or regency area as the location of the Organizing Bank's office network where the Agent is affiliated. b. In the event that the Organizing Bank's office network is not available in the city or regency area where the prospective Agent is located, the prospective Agent's location may be in a different city or regency area from the Organizing Bank's office location where the prospective Agent will be affiliated, provided that:

1. there is an Organizing Bank office network in the city or regency area bordering the prospective Agent's location; or
2. there is no Organizing Bank office network as referred to in item 1), but there is an Organizing Bank office network in another city or regency area different from the prospective Agent's location, and employees from that Organizing Bank office network can still conduct direct monitoring and supervision; and
3. adequate financial services are not yet available at the prospective Agent's location.
   c. Agent locations owned by the Regional Government Organizing Bank can only be located in the same province as the province where the Organizing Bank is located.
   In the event of a new province resulting from splitting, the Regional Government-owned Organizing Bank may have Agents in the new province as long as no Regional Government-owned Organizing Bank has been established in the split province. d. Individual Agents may only implement Laku Pandai at 1 (one) location in accordance with their permanent business activities.

2. Mechanism for Relocating Agents
   a. Agents may relocate their business activities in the event of a change in the location of the permanent business activity of an individual Agent or a change in the designation of the retail outlet network from a legal entity Agent, by submitting a relocation application. b. Agents may only relocate as long as the new location remains in the same village or sub-district as stated in the cooperation agreement, and the application for relocation of the Agent's business activities has been approved by the Organizing Bank.
   c. In granting approval as referred to in letter b, the Organizing Bank considers, among others, the potential of the community in the new location and the supervisory reach by employees of the Organizing Bank's office network where the Agent is affiliated.
   d. In the event that the Agent's relocation results in a move from the village or sub-district as stated in the cooperation agreement, the agency at the initial location is closed and then a new agency is opened at the new location.

H. Supporting Devices for the Implementation of Laku Pandai

1. The Organizing Bank must provide:
   a. technical guidelines for the implementation of Laku Pandai for Agents, including procedures for opening savings accounts with BSA characteristics, procedures and mechanisms for receiving credit or financing application documents from micro customers, and mechanisms for handling customer complaints; and b. operational support equipment for Agents, including brochures, leaflets, starter packs, forms for opening savings accounts with BSA characteristics, forms for credit or financing applications from micro customers, appointment letters, and Agent identification.
2. The Organizing Bank must ensure the readiness of other supporting services such as physical cash security both at the Agent's location and during transit between the Agent's location and the nearest Organizing Bank office.
3. In order to mitigate risks faced by the Organizing Bank, Agents, and served customers, the Organizing Bank may consider seeking protection programs for Agents, including life insurance and/or property insurance such as fire insurance, cash in transit insurance, burglary insurance, and/or cash in safe insurance.

I. Termination of Cooperation

1. The Organizing Bank must have a mechanism for determining and imposing sanctions, and terminating cooperation in the event that the Agent commits acts such as:
   a. charging fees to customers other than those established by the Organizing Bank; b. offering financial services other than those:

1. agreed upon in the cooperation agreement with the Organizing Bank,
2. agreed upon in the cooperation agreement with other financial service institutions, and/or
3. approved by the competent authority;
   c. fraud, dishonesty, and/or other misuse;
   d. moving, relocating, or closing the business without prior notification to the Organizing Bank; e. not renewing its business license with the competent authority; f. experiencing losses that are estimated to disrupt the continuity of Laku Pandai implementation; and/or g. violating regulations governing Laku Pandai.

2. The Organizing Bank must announce the plan to terminate cooperation with the Agent through appropriate media to the Organizing Bank's customers and the local community.
3. The Organizing Bank must ensure the fulfillment of the rights and obligations of all parties, including the Agent, customers, and the local community, at the latest 14 (fourteen) calendar days since the termination of cooperation is declared effective.
4. The Organizing Bank must immediately withdraw the Agent's appointment letter, Agent identification, implementation technical guidelines, operational support equipment, and the Agent's access rights, after cooperation termination is carried out, and ensure that the Agent in question no longer implements Laku Pandai.
5. Agents whose cooperation is terminated may conduct Laku Pandai activities with other Organizing Banks, after passing 20 (twenty) working days since the termination of cooperation is declared effective.
6. The Organizing Bank reports the termination of cooperation with the Agent in periodic reports on the development of Laku Pandai implementation to the Financial Services Authority (OJK).

J. Publication of Laku Pandai Agent List

1. The Organizing Bank must provide facilities and/or media for checking the validity of Agents for customers.
2. The facilities and/or media as referred to in item 1 include, among others, a list of Agents published through the Organizing Bank's website, an Agent checking feature available in customers' electronic devices such as mobile phones, and/or information on checking Agent validity through the call center.
3. The list of Agents published through the website must contain at least the following information:
   a. Agent name; b. Agent identification number;
   c. Agent location (village or sub-district); and
   d. information on the Organizing Bank's office network, where the Agent is affiliated.
4. The Organizing Bank must periodically update the list of Agents on the website, checking features, and/or call center.

K. Miscellaneous

1. The Organizing Bank must have a call center to handle problems faced by Agents.
2. In selecting prospective Agents, the Organizing Bank needs to consider the quality of the communication network supporting smooth transaction processes, including stable signals and no blank spots if the prospective Agent uses a mobile phone.
3. The Organizing Bank may use third parties to support the implementation of Laku Pandai but limited to work not related to supervision of the Agents, while still referring to regulations governing, among others:
   a. the prudential principle for Banks that delegate part of their work implementation to others; and b. the application of risk management in the use of information technology by Banks.

VI. INFORMATION TECHNOLOGY
A. Banks collaborating with Agents must be supported by information technology facilities that apply principles of data security control and e-banking transaction security in electronic systems, at least as follows:

1. Confidentiality Principle.
   The Organizing Bank ensures that the methods and procedures used can protect the confidentiality of customer data.

2. Integrity Principle.
   The Organizing Bank ensures that the methods and procedures used are able to protect data so that it is accurate, reliable, consistent, and proven true, thereby avoiding errors, fraud, manipulation, misuse, and data destruction.

3. Availability Principle.
   The Organizing Bank ensures the availability of services and electronic systems used continuously in the implementation of Laku Pandai.

4. Principle...

5. Principle of authentication. The Organizing Bank must be able to test the authenticity of the identity of customers and Agents to ensure that information provided and/or financial transactions are conducted by the entitled customer and/or the designated Agent.

6. Principle of non-repudiation.
   The Organizing Bank must formulate, establish, and implement procedures that ensure that transactions conducted by customers and/or Agents cannot be denied and can be accounted for.

7. Principle of authorization control in systems, databases, and applications (authorization control).
   The Organizing Bank ensures among others:
   a. the existence of controls over access rights and appropriate authorization regarding the systems, databases, and applications used in the implementation of Laku Pandai; b. all information and data regarding the implementation of Laku Pandai that is confidential can only be accessed by parties who have authorization and must be maintained securely and protected from the possibility of being known or modified by unauthorized parties.

8. Principle of segregation of duties and responsibilities (segregation of duties).
   The Organizing Bank ensures the existence of a separation of duties and responsibilities regarding the systems, databases, and applications used in the implementation of Laku Pandai to implement the check and balance function, such as the separation of duties between parties who initiate or input data and parties responsible for verifying and/or authorizing the truthfulness of such data.

9. Principle of maintenance of audit trails.
   The Organizing Bank ensures the availability and maintenance of transaction logs in accordance with data retention policies and applicable statutory regulations, so that there are clear audit trails to assist in proving and resolving disputes and detecting attempts to penetrate electronic systems. The Organizing Bank must analyze and evaluate the audit trail function periodically.

B. The Organizing Bank ensures the readiness of information technology infrastructure and other supporting infrastructure, including the availability of:

1. application systems used by Agents;
2. data centers, disaster recovery centers, and transaction processing based on technology for the implementation of Laku Pandai located within Indonesian territory;
3. information technology capable of processing and recording transactions in real time up to the customer's account at the Organizing Bank;
4. mechanisms for handling problems occurring in the application systems used on electronic devices at Agent locations, such as error message notifications;
5. limit management to restrict transactions that can be conducted by Agents and BSA account holders in accordance with the Organizing Bank's policies that meet applicable regulations. Application systems must be able to send notifications to BSA account holders approaching the established limits;
6. securing transaction processes by applying at least two-factor authentication during the confirmation of BSA account opening and/or transaction confirmation by customers;
7. transaction time-out management;
8. application systems capable of providing transaction proofs or notifications in real time to customers and/or Agents regarding successful transactions along with transaction nominal information or failed transactions;
9. application systems to analyze transaction history for the purpose of detecting suspicious financial transactions;
10. systems to ensure data communication security during the transmission of data from Agent systems to Organizing Bank systems or vice versa by applying among others messaging security and end-to-end encryption;
11. systems capable of ensuring the security of all customer and/or transaction data stored in Agent electronic devices, among others by applying encryption;
12. physical and logical security for information technology facilities used at Agents to mitigate risks such as theft of electronic devices, skimming, man-in-the-middle attacks, and keyloggers;
13. SOPs for handling system failures at Agents and/or the Organizing Bank, including disaster recovery and business continuity planning; and
14. SOPs for maintaining information technology facilities used at Agents or the Organizing Bank, including monitoring and evaluation.

C. The Organizing Bank may determine the use of different electronic devices among Agents using integrated application systems so that transaction settlement can be carried out in real-time online.

D. The Organizing Bank ensures that electronic devices used by Agents are able to provide services to customers according to standards established by the Organizing Bank.

E. The Organizing Bank provides information technology systems that support the use of electronic devices and/or instruments used by customers according to standards established by the Organizing Bank. In the event that the Organizing Bank determines the use of different electronic devices and/or instruments for customers in one area compared to other areas, the Organizing Bank provides systems that allow the use of such electronic devices and/or instruments.

F. In the event that the electronic device used by customers is a mobile phone (handphone/HP), the Organizing Bank ensures that the HP number must be registered and linked with the account number at the Organizing Bank.

G. In the event that opening a savings account with BSA characteristics at an Agent uses electronic forms accompanied by supporting documents (identity documents and photos) in electronic form (e-document) and involves electronic signing, the Organizing Bank, in setting requirements for electronic documents and electronic signatures and electronic systems, must refer to statutory regulations governing electronic information and transactions.

H. The Organizing Bank conducts audits of all information technology facilities related to the implementation of Laku Pandai with adequate frequency and scope based on risk analysis results and monitors the follow-up of audit results.

VII. EDUCATION AND CUSTOMER PROTECTION
A. Education

1. The Organizing Bank and/or Agents must conduct education for customers and/or the public regarding among others:
   a. benefits, risks, and costs of Laku Pandai products; b. procedures for using electronic devices and/or instruments that customers will use to conduct financial transactions in order to reduce potential losses due to operational risks;
   c. security procedures that must be carried out by customers, including:

1. maintaining the confidentiality of user names and passwords or Personal Identification Numbers (PIN),
2. periodically updating passwords or PINs,
3. not providing personal information to unrelated third parties such as names, addresses, account numbers, and mothers' maiden names,
4. requesting (including saving) transaction proofs or notifications every time a transaction is made,
5. being cautious and careful in transactions, and
6. preventing the misuse of electronic devices and/or instruments by other parties;
   d. procedures for identifying Agents; e. procedures for blocking and/or replacing account numbers in certain conditions, such as the loss of mobile phones used as electronic devices to conduct transactions related to BSA; f. wise financial management; and g. procedures for accessing complaint services (call centers) and/or submitting complaints to the Organizing Bank.

2. The implementation of education as referred to in item 1 can be carried out by:
   a. providing oral explanations or information to customers and/or potential customers supported by the provision of educational modules in the form of booklets, leaflets, or brochures; and/or b. providing information to the local community through mass media or local community leaders.

3. The implementation of education as referred to in items 1 and 2 is synergized with the Organizing Bank's education programs as regulated in provisions regarding consumer protection in the financial services sector.

B. Transparency of Information to Customers

1. The Organizing Bank must provide written information that is easily visible at Agent business locations and easily understood by customers and/or potential customers.

2. Written information regarding the Organizing Bank includes among others:
   a. the name and/or logo of the Organizing Bank; b. the complaint service phone number and information on the address of the nearest designated Organizing Bank office to handle customer complaints; and
   c. a statement that the Organizing Bank is registered and supervised by the Financial Services Authority.

3. Written information regarding Agents includes among others:
   a. the Agent appointment letter as referred to in Section V letter D; b. the Agent identification mark as referred to in Section V letter F; and
   c. Agent classification.

4. Information regarding products and/or services includes among others:
   a. a list of services provided by Agents or Organizing Bank offices and associated costs for each service; b. a summary of product and/or service information containing at least benefits, risks, and costs as well as terms and conditions; and
   c. information containing matters that require customer attention, i.e., what must be done and what must not be done (do’s and don’ts).

Example:
What must be done (Do’s)
What must not be done (Don’ts)
Customers must receive transaction proofs and/or notifications every time they transact at an Agent.
Customers must not deposit identity cards (originals) with Agents.
Customers pay attention to the maximum transaction limits for cash withdrawals, transfers, and/or outgoing transfers that can be conducted in 1 (one) month.
Customers must not provide personal identification numbers (PINs) and/or passwords to other parties including Agents.
Customers check personal information input by Agents during account opening.
Customers must not pay additional fees other than those listed in the service types and associated costs list.
Customers perform verification after completing a transaction.
Customers must not deposit money at Agents in the event of system problems at Agents and/or the Organizing Bank.
Customers remember the complaint service number (call center) of the Organizing Bank.
Customers check the amount of cash withdrawn before leaving the Laku Pandai Agent.

Such information is contained in written forms such as posters, leaflets, and/or brochets that are easy to see and read by customers or potential customers when visiting Agent locations.

C. Confidentiality and Security of Customer Data and/or Information

1. The Organizing Bank must obtain written consent from BSA account holders if the Organizing Bank intends to provide and/or disseminate customer personal data to third parties for commercial purposes.

2. In requesting consent from BSA account holders as referred to in item 1, the Organizing Bank must first explain the purpose and consequences of providing and/or disseminating customer personal data to third parties.

3. BSA account holders' consent to the Organizing Bank's request is carried out by signing a special form created for that purpose.

D. Handling Complaints

1. Handling complaints is the responsibility of the Organizing Bank.

2. The Organizing Bank must have a call center that handles complaints from customers holding savings accounts with BSA characteristics.

3. In the complaint handling and resolution mechanism, specifically for the implementation of Laku Pandai, the Organizing Bank may add complaint channels through Agents in addition to channels already available at the Organizing Bank.

4. The Organizing Bank informs BSA account holders about the importance of receipts for every transaction, which can be used as evidence when filing complaints or for court needs.

5. In the event of compensation to BSA account holders, the Organizing Bank must ensure that compensation handling meets provisions regarding consumer protection in the financial services sector.
   In the event that the Organizing Bank believes the loss occurred due to internal bank problems and the evidence shown by the customer is valid, the Organizing Bank immediately compensates the BSA account holders.

6. The Organizing Bank handles and resolves every customer complaint within a reasonable time according to the problem, urgency, and conditions faced by the customer. The maximum complaint resolution timeframe is as regulated in provisions regarding consumer protection in the financial services sector.

7. The Organizing Bank monitors trends in complaints from BSA account holders and reports them in the development reports of Laku Pandai implementation to the Financial Services Authority.

VIII. REPORTING ON THE IMPLEMENTATION OF LAKU PANDAI
A. The Organizing Bank must submit:

1. a report on the implementation of Laku Pandai for the first time, at the latest 15 (fifteen) working days after Laku Pandai begins implementation, containing at least the following information:
   a. the date of Laku Pandai implementation, b. the Agent location (regency/city), and
   c. the number and type of Agents (individuals or legal entities);
2. a report on plans to add cooperation with Agents in the context of implementing Laku Pandai every year in the Annual Business Plan (RBB) of the relevant year, containing at least the following information:
   a. the Agent location (regency/city), and b. the number and type of Agents (individuals or legal entities);
3. a report on the realization of cooperation with Agents simultaneously with the realization reports of the Annual Business Plan (RBB) as per applicable regulations, containing at least the following information:
   a. the Agent location (regency/city), and b. the number and type of Agents (individuals or legal entities);
4. The Development Report on the Implementation of Laku Pandai is submitted quarterly for the positions of March, June, September, and December.
   The format of the Development Report on the Implementation of Laku Pandai is as referred to in the Appendix, which is an integral part of this Financial Services Authority Circular;
5. A report on the first cooperation plan with legal entity Agents who have previously cooperated with other Organizing Banks conducting similar business activities is submitted at least 7 (seven) working days before the cooperation is conducted, containing at least the following information:
   a. the planned date of cooperation, b. the name of the legal entity Agent candidate,
   c. the name of the other Organizing Bank that has previously cooperated with the Agent candidate, and
   d. the retail outlet network area (regency/city).

Example of cooperation plan submission deadline:
Bank B plans to cooperate with Agent W (a legal entity) on March 13, 2015. Agent W had previously cooperated with Bank C.
The cooperation plan report must be submitted to the Financial Services Authority on or before March 4, 2015.

B. Reports as referred to in letter A are submitted to:

1. The Banking Supervision Department, Islamic Banking Department, or Financial Services Authority Regional Office in Jakarta, for Organizing Banks headquartered in the Jabodetabek area; or
2. The Regional Office or local Financial Services Authority Office, for Organizing Banks headquartered outside the Jabodetabek area,
   with a copy to the Banking Research and Regulation Department, in the event that the reports referred to in letter A item 4 are still submitted offline.

IX. CLOSING
Provisions in this Financial Services Authority Circular take effect on the date of issuance.
To be known by everyone, this Financial Services Authority Circular is ordered to be announced by placing it in the State Gazette of the Republic of Indonesia. Established in Jakarta On the date of 6 February 2015 EXECUTIVE HEAD OF BANKING SUPERVISION FINANCIAL SERVICES AUTHORITY, Signed, NELSON TAMPUBOLON STATE GAZETTE YEAR 2015 NUMBER 12 DATE 10 FEBRUARY 2015 Copy matches the original Legal Director I Legal Department, Signed, Signed, Sudarmaji

LAKU PANDAI IMPLEMENTATION DEVELOPMENT REPORT BANK ...
7. Customer Problem Reports and Follow-up Resolution
Number
Agent Identification Number
Agent Type
Agent Location *)
Customer Problem
Obstacle/
Cause of Problem
Indication
Loss Amount
*)
Follow-up Resolution
Bank Official
Responsible for Resolution
Notes: *) in the event that transactions are conducted at an Organizing Bank office, this column is filled with the name of the Organizing Bank office network ) Agent Type, filled with 1 for individual Agents and 2 for legal entity Agents *) Filled with the regency/city code of the Agent location according to the regency/city location code list for all of Indonesia on the General Bank Report (LBU) ) Obstacle note number 1 system failure 2 communication network failure 3 other obstacles (specify) *) loss amount indication is filled in full Rupiah on February 6, 2015 EXECUTIVE HEAD OF BANKING SUPERVISION FINANCIAL SERVICES AUTHORITY, Signed, NELSON TAMPUBOLON Agent Name *) Copy matches the original Legal Director I Legal Department, Signed, Signed, Sudarmaji

LAKU PANDAI IMPLEMENTATION DEVELOPMENT REPORT BANK ...

1. Laku Pandai Agent Report (New) and Changes to Laku Pandai Agents *)
   Postal Code Latitude -
   Longitudinal
   Regency/
   City
   (b) (c) (d) (e) (f) (g) (h) (i) (j) (k) (l) (m) Notes: *) The Agents referred to in this report are Agents who have newly cooperated or experienced changes in Agent classification/Location/electronic device (a) Agent Name is the name of the individual Agent owning the business activity and/or permanent income source or the name of the legal entity owning the outlet network (b) Identification number of each Agent outlet (c) Number and date of the cooperation agreement signed by the Organizing Bank with the Agent (d) Date of Laku Pandai Implementation at the outlet (e) Agent Type, filled with 1 for individual Agents and 2 for legal entity Agents (f) Agent Classification (A/B/C/D/E/F/G) according to the classification established by the Organizing Bank (g) Agent business type according to the economic sector code in Form 11 (Detail of Credit Extended) on the General Bank Report (LBU)) (h) Filled with the postal code number (i) Latitude is filled with the latitude coordinates of the Agent location, Longitude is filled with the longitude coordinates of the Agent location (coordinates are filled with decimals) (j) Filled with the regency/city code of the Agent location according to the regency/city location code list for all of Indonesia on the LBU (k) Electronic devices used by Agents, including EDC, mobile phones, and computers (l) Organizing Bank office network where the Agent is affiliated (m) Notes are filled with numbers indicating the Agent development status, namely:
   1 = New Agent
   2 = Change in Agent classification
   3 = Change in Agent business type
   4 = Change in Agent location
   5 = Termination of Agent due to violations
   6 = Termination of Agent due to expiration of cooperation term without renewal 7 = Change and/or addition of electronic devices 8 = Passive Agent (Agents that have not actively served transactions for more than 90 days) (a) Electronic Device Used Business Type Agent Agent Location Agent Name Notes Number Agent Identification Number and Date Cooperation Agreement Date Implementation Agent Type Agent Classification Office Network Bank

LAKU PANDAI IMPLEMENTATION DEVELOPMENT REPORT BANK ... -2- 2 a. Quantitative Data on Laku Pandai Implementation (conventional) Number Accounts Nominal Initial Deposit ) Frequency Transactions Nominal ) Frequency Transactions Nominal ) Frequency Transactions Nominal ) Frequency Transactions Nominal ) Frequency Transactions Nominal ) Number Accounts Nominal ) Number Debtors Nominal ) Notes: *) in the event that transactions are conducted at an Organizing Bank office, this column is filled with the name of the Organizing Bank office network ) Agent Type, filled with 1 for individual Agents and 2 for legal entity Agents *) Filled with the regency/city code of the Agent location according to the regency/city location code list for all of Indonesia on the LBU ) nominal is filled in full Rupiah Agent Name *) Number Agent Identification Number Agent Type ) Location Agent *) Total BSA Opening Total Transfers Total BSA Closure Total Micro Credit Applications by Location Agent Customers BSA *) Total Cash Deposits Total Cash Withdrawals Total Bill Payments Total Interbank Transfers

LAKU PANDAI IMPLEMENTATION DEVELOPMENT REPORT BANK ...
2 b. Quantitative Data on Laku Pandai Implementation (based on Sharia principles) Number Accounts Type Contract Nominal Initial Deposit ) Frequency Transactions Nominal ) Frequency Transactions Nominal ) Frequency Transactions Nominal ) Frequency Transactions Nominal ) Frequency Transactions Nominal ) Frequency Transactions Nominal ) Number Debtors Type Contract Nominal ) Notes: *) in the event that transactions are conducted at an Organizing Bank office, this column is filled with the name of the Organizing Bank office network ) Agent Type, filled with 1 for individual Agents and 2 for legal entity Agents *) Filled with the regency/city code of the Agent location according to the regency/city location code list for all of Indonesia on the LBU ) nominal is filled in full Rupiah Total Micro Financing Applications by BSA Customers Agent Name *) Number Agent Identification Number Agent Type ) Location Agent *) Total BSA Opening Total Cash Deposits Total Cash Withdrawals Total Bill Payments Total Transfers Total Interbank Transfers Total BSA Closure

LAKU PANDAI IMPLEMENTATION DEVELOPMENT REPORT BANK ...
3 a. Service Rejection Data in Laku Pandai Implementation (conventional) Account Reason ) Transaction Reason ) Transaction Reason ) Transaction Reason ) Transaction Reason ) Transaction Reason ) Account Reason ) Account Reason ) Notes: *) in the event that transactions are conducted at an Organizing Bank office, this column is filled with the name of the Organizing Bank office network ) Agent Type, filled with 1 for individual Agents and 2 for legal entity Agents *) Filled with the regency/city code of the Agent location according to the regency/city location code list for all of Indonesia on the LBU ) Reason is filled with:
note number
1 Incomplete documents
2 Incorrect documents
3 Failed customer due diligence
4 Agent account balance insufficient
5 Customer account balance insufficient
6 Transaction will exceed debit account limits 7 Dormant account not reactivated 8 Transaction conducted by unauthorized party 9 Financial transactions potentially suspicious 10 Suspected counterfeit money 11 Others (specify) Agent Name *) Number Agent Identification Number Location Agent *) Agent Type ) Total Micro Credit Rejections Total BSA Closures Total BSA Opening Rejections Total Cash Deposit Rejections Total Cash Withdrawal Rejections Total Bill Payment Rejections Total Interbank Transfer Rejections Total Transfer Rejections

REPORT ON THE DEVELOPMENT OF BANK LAKU PANDAI IMPLEMENTATION ...

3b. Data on Service Rejections in the Implementation of Laku Pandai (based on Sharia principles)

Account Type	Reason for Rejection	Transaction Reason	Reason for Rejection	Transaction Reason	Reason for Rejection	Transaction Reason	Reason for Rejection	Transaction Reason	Reason for Rejection
Account Reason
Account Type
Reason

Notes:
*) In the event that transactions are conducted at the Organizer Bank's office, this column is filled with the name of the Organizer Bank's office network.
*) Agent Type, filled with 1 if Individual Agent and 2 if Legal Entity Agent.
*) Filled with the district/city code where the Agent's location is situated according to the district/city location code list for all of Indonesia in the LBU. *) Reasons are filled with:

Number	Description
1	Incomplete documents
2	Incorrect documents
3	Failed customer due diligence
4	Insufficient Agent account balance
5	Insufficient customer account balance
6	Transaction would exceed the debit limit of the account
7	Dormant account not yet reactivated
8	Transaction conducted by unauthorized party
9	Financial transaction with suspicious potential
10	Suspected counterfeit money
11	Others (specify)

Micro Agent Name *)	Agent Identification Number	Agent Type *)	Agent Location *)	Total Financing Rejections

Total BSA Opening Rejections	Total Cash Deposit Rejections	Total Cash Withdrawal Rejections	Total Bill Payment Rejections	Total Transfer Rejections	Total Interbank Transfer Rejections	Total BSA Closures

REPORT ON THE DEVELOPMENT OF BANK LAKU PANDAI IMPLEMENTATION ...

4. Report on Dormant BSA Accounts

Number of Accounts	Account Nominal *)

Notes:
*) Branch code of the Organizer Bank according to the reporting bank's office code according to LBU regulations.
*) Account nominal is filled in full Rupiah.

Branch Code *)

REPORT ON THE DEVELOPMENT OF BANK LAKU PANDAI IMPLEMENTATION ...

5. Report on Violations Committed by Laku Pandai Agents and Follow-up on Their Resolution

Agent Identification Number	Agent Type *)	Agent Location *)	Agent Violation *)	Cause of Violation	Indication of Loss Amount *)	Follow-up	Name of Bank Official Responsible for Follow-up

Notes:
*) In the event that transactions are conducted at the Organizer Bank's office, this column is filled with the name of the Organizer Bank's office network.
*) Agent Type, filled with 1 if Individual Agent and 2 if Legal Entity Agent.
*) Filled with the district/city code where the Agent's location is situated according to the district/city location code list for all of Indonesia in the LBU. *) Agent Violations:

Number	Description
1	Imposing additional fees on customers other than those established by the Organizer Bank
2	Offering financial services other than those agreed upon in the cooperation agreement with the Organizer Bank/Other Financial Service Institution/competent authority
3	Fraud, dishonesty and/or other abuse by the Agent
4	Other issues (specify)

*) Indication of loss amount is filled in full Rupiah.

Agent Name *)

REPORT ON THE DEVELOPMENT OF BANK LAKU PANDAI IMPLEMENTATION ...

6. Report on Laku Pandai Agent Issues and Follow-up on Their Resolution

Agent Identification Number	Agent Type *)	Agent Location *)	Agent Issue	Obstacle/Cause of Issue *)	Indication of Loss Amount *)	Follow-up Resolution	Bank Official Responsible for Resolution

Notes:
*) In the event that transactions are conducted at the Organizer Bank's office, this column is filled with the name of the Organizer Bank's office network.
*) Agent Type, filled with 1 if Individual Agent and 2 if Legal Entity Agent.
*) Filled with the district/city code where the Agent's location is situated according to the district/city location code list for all of Indonesia in the LBU. *) Obstacles:

Number	Description
1	System disturbance
2	Communication network disturbance
3	Customer complaints
4	Other obstacles (specify)

*) Indication of loss amount is filled in full Rupiah.

Agent Name *)

REPORT ON THE DEVELOPMENT OF BANK LAKU PANDAI IMPLEMENTATION ...

7. Report on Customer Issues and Follow-up on Their Resolution

Agent Identification Number	Agent Type *)	Agent Location *)	Customer Issue	Obstacle/Cause of Issue *)	Indication of Loss Amount *)	Follow-up Resolution	Bank Official Responsible for Resolution

Notes:
*) In the event that transactions are conducted at the Organizer Bank's office, this column is filled with the name of the Organizer Bank's office network.
*) Agent Type, filled with 1 if Individual Agent and 2 if Legal Entity Agent.
*) Filled with the district/city code where the Agent's location is situated according to the district/city location code list for all of Indonesia in the LBU. *) Obstacles:

Number	Description
1	System disturbance
2	Communication network disturbance
3	Other obstacles (specify)

*) Indication of loss amount is filled in full Rupiah as of February 6, 2015.

Agent Name *)

EXECUTIVE HEAD OF BANKING SUPERVISION
FINANCIAL SERVICES AUTHORITY,

Signed,

NELSON TAMPUBOLON

Copy matches the original

Legal Director I
Legal Department,

Signed,

Sudarmaji

REPORT ON THE DEVELOPMENT OF BANK LAKU PANDAI IMPLEMENTATION ...

7. Report on Customer Issues and Follow-up on Their Resolution

Agent Identification Number	Agent Type *)	Agent Location *)	Customer Issue	Obstacle/Cause of Issue *)	Indication of Loss Amount *)	Follow-up Resolution	Bank Official Responsible for Resolution

Notes:
*) In the event that transactions are conducted at the Organizer Bank's office, this column is filled with the name of the Organizer Bank's office network.
*) Agent Type, filled with 1 if Individual Agent and 2 if Legal Entity Agent.
*) Filled with the district/city code where the Agent's location is situated according to the district/city location code list for all of Indonesia in the LBU. *) Obstacles:

Number	Description
1	System disturbance
2	Communication network disturbance
3	Other obstacles (specify)

*) Indication of loss amount is filled in full Rupiah as of February 6, 2015.

EXECUTIVE HEAD OF BANKING SUPERVISION
FINANCIAL SERVICES AUTHORITY,

Signed,

NELSON TAMPUBOLON

Copy matches the original

Legal Director I